(1) Shut down and decommissioned the Isom unit to abate all hazardous conditions that contributed to the Isom incident;

(2) Abated more than 300 process safety, electrical, and other deficiencies alleged to exist at the Texas City Refinery;

(3) Expanded safety and health training at the Texas City Refinery;

(4) Retained, with the concurrence of OSHA, a qualified expert in the PSM field ("PSM Expert") to perform a comprehensive PSM systems audit, issue an audit report, conduct three semi-annual follow-up progress assessments, and issue three semi-annual progress reports;

(5) The PSM Expert issued 228 recommendations; BP Products accepted 220 of the recommendations Prepared and submitted to OSHA a statement of action to be taken on the 220 recommendations and submitted follow-up progress reports and implemented the recommendations (though the FTAN alleges that 4 recommendations related to safety instrumented systems were not implemented);

(6) BP Products retained an independent expert to conduct an audit of the adequacy of the methodology and engineering analysis the Refinery applied to its hydrocarbon pressure relief systems by examining these issues at Pipestill 3B and the Ultracracker. BP Products submitted a report of the findings and recommendations to OSHA and has implemented all 100 of the recommendations (though the FTAN alleges the audit should have been extended to the remaining process units at the Refinery).

(7) Retained, with the concurrence of OSHA, a qualified expert in the organizational communication, behavior, and analysis field ("Organizational Expert") to assess communication within the Texas City Refinery with respect to safety and safety commitment and to issue an interim and final report;

(8) Prepared and submitted to OSHA a statement of action to be taken on the recommendations set forth in the Organizational Expert’s interim and final reports and implemented the Organizational Expert’s feasible recommendations;
(9) Submitted occupational injury and illness logs to OSHA semi-annually;

(10) Investigated and notified OSHA of any accident or injury involving PSM and/or Lockout-Tagout that resulted in one or more days of lost work-time; and

This Exhibit 3 describes the equipment based revalidation process BP Products will implement to evaluate all of its process relief systems inside unit battery limits.

BP Products will collect and ensure the accuracy of key information required to conduct the relief systems revalidation analysis. That information will include the following:

Heat and material balances-This includes the physical properties of the fluids in the system, the rate of fluid movement within the system, temperatures, pressures, fluid properties, and whether the material is a vapor, gas, liquid, or two phase.

Relief device information such as the relief device set points, blowdown, coefficients, type, manufacturer, model, orifice area, capacity, test pressure, and discharge location including whether it discharges to the atmosphere or to a flare.

Piping and instrumentation diagrams (P&IDs).

Equipment information such as the pressure vessels protected by the relief device, pressure vessel metallurgy, the applicable code to which the pressure vessel was constructed, maximum allowable working pressure or design pressure, and vessel dimensions.

Other data such as the piping used in the relief system, piping metallurgy, inlet and outlet size, and location of block valves within the system.

Process flow diagrams (PFDs) or sketch.

Operating conditions.

Piping sketches.

Field verification of data identified above, where needed.

Conduct or confirm which pressure relief scenarios are credible within the relevant relief system. This is accomplished by reviewing the 21 scenarios defined in BP Products's engineering practices. This review identifies the reasons and causes of the overpressure. The rationale for inclusion or exclusion of these 21 scenarios will be documented in the associated relief device and system folders. Engineering design calculations are then performed to determine the adequacy of overpressure protection for all applicable scenarios.

Conduct or confirm the adequacy of flare and effluent system according to BP GP 44-80 such as the hydraulic capacity of the flare header piping, the flare knockout drum, and radiation from the flare tip. This analysis will be done for various relief scenarios, such as loss of power and loss of cooling. The results of these analyses are documented in a clear and consistent format and made readily accessible.

Identify all potential hazards of a device relieving to atmosphere as required by API 521.

The following relief system calculations are typically made using the relevant equations from API 520 and 521 and BP Products engineering practices:

Required flow rate based on applicable overpressure scenarios and the capacity of the relief device for each of the scenarios.

Relief stream conditions used for sizing the relief devices and performing any required hydraulic calculations.

Hydraulic loads on the relief system during various release scenarios.

Flare header analysis and hydraulic calculations based on global scenarios.

Flare header knockout drum sizing calculations.

Determination of radiation levels from any flare tips.

Fluid properties generation using process simulations.

Using the information collected in Sections 1-3 and the calculations conducted in Section 5 of this exhibit, BP Products will identify, assess, validate, rank, and take interim mitigation steps to address gaps found during the revalidation process.

Key documentation developed during the activities described in Sections 1-5 of this exhibit will be included in the appropriate relief system folder. The Refinery maintains its relief system design documentation as follows: a) Relief Device Folder, b) Protected System Folder, and c) Effluent Book.

Table 1 Equipment not included in the Relief System - Equipment-Based Revalidation

Note 1: The process side of exchangers that utilize these utilities shall be analyzed for relief issues (e.g. tube rupture case) that would put hydrocarbons into the utility system.

Note 2: Thermal relief valves are maximum 1x2 relief valves with D orifice; installed only to protect against fluid thermal expansion in piping/equipment that is liquid full and isolated. Typically these are in OSBL areas; although there may be some in process areas.

Exhibit 4CONTENTS OF RELIEF DEVICE FOLDER

This Exhibit 4 describes the contents of the Refinery's relief device folders.

Relief device cover sheet- This summarizes key parameters about the relief device, its design basis, and the analyses performed that are described in Exhibit 3.

Relief device datasheet- This summarizes relief device specifications and design basis such as the controlling scenario to which it may potentially be subjected and the relief device size, orifice size, set pressure, area, model, make, and process information required for the controlling scenario.

Scenarios summary sheet- This summarizes the process information and relief loads for all applicable overpressure scenarios. This information is a summary from the detailed calculations described in Exhibit 3.

A field sketch of the relief device inlet and outlet piping, including inlet and outlet equivalent length calculations.

Vendor information for the relief device, as applicable.

Exhibit 5CONTENTS OF PROTECTED SYSTEM FOLDER

A protected system as that term is used by the Refinery means the smallest related group of relief valves, piping, and process vessels that can be completely isolated from other systems by closing various isolation valves. This group of relief valves, piping, and process vessels only includes such equipment that would necessarily be subject to the same overpressure event at the same time as a result of the process and relief system designs. The protected system typically is part of a Process Unit, and is associated with an effluent (discharge) system.

This Exhibit 5 describes the contents of the Refinery's protected system folders.

1. Protected system executive summary-This summarizes the equipment and piping in the pressurized relief system including unique pressure vessel and piping identification numbers, and identification of the engineering drawings (P&ID) on which they are located, the results of the overpressure protection system design, and list of potential design issues, if applicable.

2. Overpressure contingency checklist-This will list each primary cause of overpressure relying on the 21 possible scenarios from BP's engineering practices, and an indication of whether or not the cause of overpressure was found to apply to the pressurized system. Each cause of overpressure should provide the rationale used for the determination of whether or not the cause of overpressure was found to apply.

3. Engineering calculation details- This documentation includes all the relief device sizing and hydraulic detailed calculations for all applicable overpressure scenarios. It is derived from the calculation software (MathCAD, or equivalent) or an equivalent calculation software used by the Refinery.

6. Protected equipment specification or data sheets, pump curves, and any auxiliary information relevant to the protected system under consideration that was used for the analyses described in this exhibit.

7. Identification of any credit taken for existing protective measures in conducting the analyses referenced in this exhibit for the prevention of various release scenarios. This may include protective measures such as unit shutdown procedures, alternative relief paths, and safety instrumented systems (for flare header analysis only).